Correspondence 0001104659-24-108070 from Paragon 28, Inc. (FNA) (CIK 0001531978)
Paragon 28, Inc. (FNA) (CIK 0001531978)
Date: Oct. 11, 2024 · CIK: 0001531978 · Accession: 0001104659-24-108070
AI Filing Summary & Sentiment
Letter
VIA EDGAR Division of Corporation Finance United States Securities and Exchange Commission Attention: Al Pavot Terence O’Brien Office of Industrial Applications and Services RE: Paragon 28, Inc. Amendment No. 1 to Form 10-K for the fiscal year ended December 31, 2023
Dear Messrs. Pavot and O’Brien:
Paragon 28, Inc. (the “Company,” “Paragon” or “we”) hereby submits via EDGAR the Company’s responses to comments received from the staff (the “Staff”) of the United States Securities and Exchange Commission set forth in the Staff’s letter to the Company, dated September 30, 2024, in relation to the above-referenced filings.
We have set forth below your comment followed by the Company’s response.
Amendment No. 1 to Form 10-K for the fiscal year ended December 31, 2023
Item 11. Executive Compensation., page 165
1. It appears that you have not provided your disclosure about your recovery analysis in an Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. Please confirm that in future filings, where you conduct a recovery analysis, the interactive data will be included.
Response:
The Company respectfully acknowledges the Staff’s comment. The interactive data for the recovery analysis was inadvertently excluded. Paragon agrees and has noted for future applicable filings that the interactive data will be included for the recovery analysis in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual.
If you require additional information, please contact me at rmccormack@paragon28.com or (720) 212-7663.
Sincerely,
/s/ Robert McCormack
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CORRESP
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filename1.htm
October 11, 2024
VIA EDGAR
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Al Pavot
Terence O’Brien
Office of Industrial Applications and
Services
RE: Paragon 28, Inc.
Amendment No. 1 to Form 10-K for
the fiscal year ended December 31, 2023
Dear Messrs. Pavot and O’Brien:
Paragon 28, Inc. (the “Company,”
“Paragon” or “we”) hereby submits via EDGAR the Company’s responses to comments received from
the staff (the “Staff”) of the United States Securities and Exchange Commission set forth in the Staff’s letter
to the Company, dated September 30, 2024, in relation to the above-referenced filings.
We have set forth below your comment followed by
the Company’s response.
Amendment No. 1 to Form 10-K for the fiscal year ended
December 31, 2023
Item 11. Executive Compensation., page 165
1. It appears that you have not provided your disclosure about your recovery analysis in an Interactive
Data File in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. Please confirm that in future filings, where
you conduct a recovery analysis, the interactive data will be included.
Response:
The Company respectfully acknowledges
the Staff’s comment. The interactive data for the recovery analysis was inadvertently excluded. Paragon agrees and has noted for
future applicable filings that the interactive data will be included for the recovery analysis in accordance with Rule 405 of Regulation
S-T and the EDGAR Filer Manual.
If you require additional information, please contact me at rmccormack@paragon28.com
or (720) 212-7663.
Sincerely,
/s/ Robert McCormack
Robert McCormack
General Counsel & Corporate
Secretary
cc:
(via email)
Chadi Chahine, Chief Financial Officer & EVP Supply Chain, Paragon 28, Inc.
Minh Van Ngo, Esq., Cravath, Swaine & Moore LLP
Michael Arnold, Esq., Cravath, Swaine & Moore LLP
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